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Costa Rica Publishes Resolution on Updated Transfer Pricing Documentation Requirements

20 November 2019

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Approved Changes

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Costa Rica

Costa Rica published Resolution DGT-R-49-2019 in the 13 November 2019 edition of the Official Gazette. The resolution updates and replaces Resolution DGT-R-16-2017, which was published in April 2017 and introduced Costa Rica's Master and Local file content requirements based on BEPS Action 13. The requirements remain in line with the Action 13 guidelines, with some adjustments. Master File The Master file (group information) should include: a chart illustrating the corporate structure of the economic group, including indication of the geographical location of the companies; the administration structure of the economic group and geographical location of key personnel; a general description...